ECOTERRA ANTI MONEY LAUNDERING ("AML")AND
KNOW YOUR CLIENT (KYC)

ECOTERRA is committed to the highest standards of Anti-Money Laundering (AML)compliance and Anti-Terrorist Financing and requires the management, and employees to follow
the named standards.
Introduction
Definitions
AML: Anti Money Laundering.
CDD: Client Due Diligence.
Client: A verified user.
ECDD: Enhanced Client Due Diligence.
ECOTERRA: when being used in this policy means EARTHUP S.R.L., a company organizedunder the laws of Romania, having its registered office address at 5 Potcoavei Str., Jud. Ilfov,
Loc. Voluntari, J23/6570/2021, CUI 45107385.
PEP: Politically Exposed Person. A PEP is a natural person who is or has been entrusted withprominent public functions as well as their family members or close associates of such persons.
Prominent public functions mean the following functions in the Romania, the European Unionand international or foreign state institutions:● heads of State, heads of government, ministers, vice-ministers or deputy ministers,
secretaries of State and chancellors of parliament, government or ministry;● members of parliament;● members of supreme courts, of constitutional courts or of other high-level judicial bodies
whose decisions are not subject to further appeal;● mayors of municipalities, directors of municipal administrations;● members of the management bodies of national supreme audit and control institutions orchairs of the boards of central banks, deputy chairs or board members;● ambassadors, commanders of military forces and units, high-ranking officers in the armed
forces of foreign states;● members of the management or supervisory bodies of state enterprises, public limited
liability companies and private limited liability companies whose shares or a part ofshares carrying more than 1⁄2 of all the votes at the general meeting of shareholders ofthese companies are held by the right of ownership by the State;

● members of the management or supervisory bodies of municipal enterprises, public
limited liability companies and private limited liability companies whose shares or a partof shares carrying more than 1⁄2 of all the votes at the general meeting of shareholders ofthese companies are held by the right of ownership by municipalities and which areconsidered to be large undertakings under the Law of Romania on Financial Reporting;● heads and deputy heads of international intergovernmental organizations and members of
their management or supervisory bodies;● heads and deputy heads of political parties and members of their management bodies.
Public key: a code of letters, numbers and/or symbols designed to identify the client andgenerate the client’s virtual currency address.
SCDD: Simplified Client Due Diligence
Threshold: Trading limit (total volume) in EUR per client.
UBO: Ultimate Beneficial Owner.
User: Any user on the EcoTerra platform with a registered user account. Not necessarily a client.
VASP: Virtual asset service providers.
Virtual currency: a digital representation of value that does not possess a legal status of
currency or money, that is not issued or guaranteed by a central bank or any other publicauthority, is not necessarily attached to a currency, but is accepted by natural or legal persons as ameans of exchange and which can be transferred, stored and traded electronically.
Virtual currency address: an address/account generated from letters, numbers and/or symbols
in the blockchain, by which the blockchain allocates the virtual currency to the owner orrecipient.
ScopeThis Policy outlines the general unified procedures, guidelines and standards of internal AML
control which would be adhered to by the company in order to mitigate the legal, regulatory,
reputational, operational, and as a consequence financial risk.
Firm Policy
It is the policy of ECOTERRA to prohibit and actively prevent money laundering and any
activity that facilitates money laundering or the funding of terrorist or criminal activities bycomplying with all applicable requirements under the implementing regulations. As the crypto
space is under continuous development, we may decide to implement any of hereinafter statedmeasures in the future, as we will deem appropriate and necessary, prior to the Markets in
Crypto-assets, and amending Directive (EU) 2019/1937 (MiCA), coming into force.
Our AML policies, procedures and internal controls are designed to ensure compliance with allapplicable regulations and rules and will be reviewed and updated on a regular basis to ensureappropriate policies, procedures and internal controls are in place to account for both changes inregulations and changes in our business.
Objectives
The objective of the guidelines is to prevent the company from being used, intentionally orunintentionally, by criminal elements for money laundering or terrorist financing activities. The
Policy also enables the company to know / understand the status of its Investors / users and theirfinancial dealings better, to manage risks including reputation.
Overview
ECOTERRA, like most companies providing services in the crypto market, adheres to theprinciples of Anti-Money Laundering and actively prevents any actions that aim or facilitate theprocess of legalizing of illegally gained funds. AML policy means preventing the use of thecompany's services by criminals, with the aim of money laundering, terrorist financing or othercriminal activity.
For this purpose, a strict policy on the detection, prevention and warning of the corresponding
bodies of any suspicious activities was introduced by the company. Moreover, ECOTERRA has
no right to report users that the law enforcement bodies are informed on their activity. A complex
electronic system for identifying every company's user and conducting a detailed history of all
operations was introduced as well.
Money laundering is generally defined as engaging in acts designed to conceal or disguise thetrue origins of criminally derived proceeds so that the proceeds appear to have derived fromlegitimate origins or constitute legitimate assets. Terrorist financing is an attempt to conceal
either the origin of the funds or their intended use, which could be for criminal purposes.
The process of money laundering can be divided into three sequential stages:
Placement. At this stage funds are converted into financial instruments, such as checks, bankaccounts, and money transfers, or can be used for purchasing high-value goods that can be
resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency
exchangers). To avoid suspicion by the company, the launderer may as well make several
deposits instead of depositing the whole sum at once, this form of placement is called smurfing.
Layering. Funds are transferred or moved to other accounts and other financial instruments. It is
performed to disguise the origin and disrupt the indication of the entity that made the multiple
financial transactions. Moving funds around and changing in their form makes it complicated to
trace the money being laundered.
Integration. Funds get back into circulation as legitimate to purchase goods and services.
In response to the scale and effect of money laundering, the United States of America and theEuropean Union has passed Laws and Directives designed to combat money laundering andterrorism. These Acts, together with other regulations, rules and industry guidance, form thecornerstone of our AML/KYC obligations and outline the offenses and penalties for failing tocomply.
Whilst ECOTERRA’s business domain is currently relatively unregulated and does not fallwithin the scope of the AML/KYC obligations, our management has decided to implement
systems and procedures that meet the standards set forth by the United States of America and theEuropean Union. This decision reflects the management’s desire to prevent money launderingand not be used by criminals to launder proceeds of crime.
ANTI-MONEY LAUNDERING POLICYECOTERRA has developed and will currently implement on a case-by-case basis a risk-based
anti-money laundering program comprising of:-Written Anti-Money Laundering Policies
Customer Identification Procedures
Anti-Fraud Procedures
Record-Keeping Requirements
Customer Risk Assessment Procedures
Sanction Lists Procedures
ECOTERRA Employees Training Procedures
On-going Customers’ activity procedures

The ECOTERRA AML Policy is designed to prevent money laundering by meeting theworldwide standards on combating money laundering and terrorism financing, including theneed to have adequate systems and controls in place to mitigate the risk of the firm being used tofacilitate financial crime. This AML Policy sets out the minimum standards which must becomplied with and includes:●

Establishing and maintaining a Risk-Based Approach (RBA) to the assessment andmanagement of money laundering and terrorist financing risks faced by the firm;●

Establishing and maintaining risk-based Customer Due Diligence (CDD), identification,verification and Know Your Customer procedures, including enhanced due diligence forcustomers presenting a higher risk, such as Politically Exposed Persons (PEPs);●

Establishing and maintaining risk-based systems and procedures for the monitoring of
on-going customer activity;●

Establishing procedures for reporting suspicious activity internally and to the relevant
law enforcement authorities as appropriate;●

Maintaining appropriate records for the minimum prescribed periods;●

Providing training for and raising awareness among all relevant employees.

We may decide, because of the company's commitment to the AML and KYC policies, that eachuser may have to finish a verification procedure. Before ECOTERRA starts a specificrelationship with the user, the company may have to ensure that satisfactory evidence isproduced or such other measures that will produce satisfactory evidence of the identity of any
customer or counterparty are taken. The company as well may apply heightened scrutiny to users
who are residents of other countries, identified by credible sources as countries, having
inadequate AML standards or that may represent a high risk for crime and corruption and tobeneficial owners who resides in and whose funds are sourced from named countries.
Risk Assessment
Key facts
If there are concerns about the validity of previous verification data, it is necessary to obtainapproval from the AML Officer before establishing or continuing business relationships withthese clients. Trading permission should be disabled and mandatory re-verification initiated. TheAML Officer decides whether to report to the competent authorities.
In the event of suspected money laundering or terrorist financing, the AML Officer must be
notified immediately, and trading permission should be disabled. Client re-verification isrequired, and the AML Officer decides whether to report to the competent authorities.
Risks that lead to the refusal of the business relationshipThe following risks automatically lead to the refusal of the business dealings, operations ortransactions:●

The client is residing in a high-risk third country as defined by the FATF (high-risk andother monitored jurisdictions) and EU Regulation 2016/1675.

●

The client is a PEP●

The client is a US-Person●

The UBO does not match with the (potential) client.

Risks that can lead to a higher risk level and the termination of the business relationshipThe following risks lead to ECDD and can lead to the termination of the business dealings,
operations or transactions and/or reporting to the competent authorities.
Client risks●

The business relationship of theclient is conducted in unusual
circumstances without any apparent
economic or visible lawful purpose;

Operational risks Country-based risks●

Payments are received • Payments arefrom unknown or
received from a
unassociated thirdbank account in aparties;non SEPA country●●

The client avoids submitting the●Complex transactions;information required●

Unusually large

The client avoids
answering questions from
Compliance Team / delays answers /does not cooperate with Compliance
Team●

User asks for special services (nontransactions;●

Transactions
conducted in an
unusual pattern;●standard)

Transactions that do
not have an apparent
economic or lawful
purpose;●Transactions conductedin an unusual pattern;●

Transactions that do
not have an apparent
economic or lawful
purpose;Operational measures when a high-risk client is detected:
1. Set high-risk level in the system if not automatically done by the system
2. Document the reason for setting the high-risk level
3. Disable trading permission of that client.
4. ECDD process
Individual users
Whenever necessary for the provision of any of the company’s permanent or temporary services,during any required process of registration, each user may have to provide any or all of thefollowing personal information: full name; email address; complete address, including phone
number and city code; date of birth; origin. For the avoidance of doubt: ECOTERRA does not
require any or all of the documents hereinafter detailed for the provision of all the services,
instead such requirements will be issued on a case-by-case basis, specifically whenever the law
or the regulation applicable to any specifically provided service may require us to do so.

A user may have to send the following documents (in case the documents are written in
non-Latin characters: to avoid any delays in the verification process, it is necessary to provide anotarized translation of the document in English) because of the requirements of KYC and to
confirm the indicated information:● a high-resolution copy of the first page of local or international ID or passport, where thephoto and the signature are clearly seen, or a copy of driver's license with the samerequirements. The indicated documents must be valid at least 6 months from the filingdate.
● a high-resolution copy of a receipt of utility services payment or bank statement,
containing the full user's name and the actual place of residence. These documents should
not be older than 3 months from the date of filing.
Client Due Diligence (CDD)
If the user wants to raise his threshold and become a client, the user needs to proceed with the
CDD process, which consists of the Identity Verification, Residency Verification and Financial
Background Check. The CDD process must be completed successfully to raise the threshold. All
automatic and manual checks by our compliance team must be successful in order to reach theclient status “verified” and complete the CDD process successfully.
Simplified Client Due Diligence (SCDD)
Required Information
Upon registration, users go through an automated verification process where they submit:● Full name;● Email address.
All submitted user information is manually reviewed. For users who cannot be verified throughautomated means (geolocation, algorithmic face detection, sanctions list check), enhanced due
diligence is requested as described below.
Second Level Client Due Diligence
Government-issued ID
Verification of identity is required by obtaining a high-resolution, non-expired copy of the user’s
government-issued ID (passport, national identity card, or a driver’s license). The submitted
imaged requirements include:• Full color image. Black and white, watermarked, etc. are not accepted;• Legible. All information on the ID must be completely clear and readable. ECOTERRA does
not accept IDs that are torn or worn out; and• Background. The edges of the ID document must be clearly visible on a contrastingbackground.
Proof of residence
Verification of residence is required by obtaining a copy of an acceptable address proof
document issued in the 3 months prior to establishing an account. The document must carry theuser’s name and address.
A valid proof of residence document can be:
●
●
●
●
●
●
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bank statement;
debit or credit card statement;utility bill (water, electricity, gas, internet, phone);
payroll statement or official salary document from employer;
insurance statement;
tax document; orresidence certificate.

Proof of residence documents must contain the user’s name, address, and be dated less than 3months ago.
Unique photo of user
Further verification is requested from users by submitting a unique photo of themselves holding
their government-issued ID as well as a unique handwritten note. In the photo, the user must be
visibly smiling. This allows ECOTERRA to easily prove that the user’s picture was not stolen or
photoshopped, and is being used exclusively for ECOTERRA.
The ID the user holds in their hand:••must be the same government-issued ID the user submitted previously; andmust be fully clear and readable.

The note the user holds in their hand:
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•
•
•
•

must be handwritten (not typed);must be in English;
must contain today's date;must contain the sentence: For trading at wcex.com only; andmust contain the user’s signature.

Verification
Based on the risk, and to the extent reasonable and practicable, we ensure that we have areasonable belief that we know the true identity of our customers by using risk-based proceduresto verify and document the accuracy of the information we get about users. Our AML

Compliance Officer analyzes the information we obtain to determine whether the information is
sufficient to form a reasonable belief that we know the true identity of the customer.
We may decide to use the following non-documentary methods of verifying identity:
•

•
•

•
•

Independently verifying the customer’s identity through the comparison of
information provided by the customer with information obtained from a consumer
reporting agency, public database or other source;
Checking references with other financial institutions;
Analyzing whether there is logical consistency between the identifying
information provided, such as the users’ name, street address, postal code, anddate of birth;
Utilizing complex device identification (such as “digital fingerprints” or IP
geolocation checks); andObtaining a notarized or certified true copy of an individual’s birth certificate or
government-issued ID for valid identification.

Corporate users
In case the applicant company is listed on a recognized or approved stock exchange or when
there is independent evidence to show that the applicant is a wholly owned subsidiary or asubsidiary under the control of such a company, no further steps to verify identity will normallybe required. In case the company is unquoted and none of the principal directors or shareholders
already has an account with ECOTERRA, the official provides the following documents:-a high-resolution copy of the certificate of incorporation/certificate;an extract from the Commercial Register, or equivalent document, evidencing theregistration of corporate acts and amendments;
names and addresses of all officers, directors and beneficial owners of the corporate
entity;a high-resolution copy of Memorandum and Articles of Association or equivalent
documents duly recorded with the competent registry;evidence of the company’s registered address and the list of shareholders and directors;
description and nature of business (including the date of commencement of the business,
products or services provided; and the location of principal business).

This procedure is performed to establish the identity of the user and to help ECOTERRA know /understand the users and their financial dealings to be able to provide the best services of online
trading.
Enhanced Client Due Diligence (ECDD)The ECDD process is initiated if there is a suspicion of money laundering or terrorist financing
or when there are doubts about the veracity or authenticity of obtained identification data of theclient (which must always be the same as the UBO). Every start of an ECDD process is also
called an internal investigation.

In the ECDD process, more data or information must be obtained from a reliable andindependent source and requested from the client. The client has to indicate public sources which
could validate the information about him, about the confirmation that he is also the beneficial
owner, about his identity or other information. Additional information and clear proof fromreliable and independent sources must also be obtained about the nature of the business
relationship and the reasons for the intended or performed transactions, as well as about thefinancial background (source of funds, source of wealth).
If the user is able to resolve the uncertainties during the ECDD process, obtain approval from the
AML Officer for establishing business relationships with such clients or continuing business
relationships with these clients. Possible outcome:a) If the client is not able to resolve the uncertainties, terminate the business relationship. Informthe AML Officer, who will decide on reporting to the competent authorities.
b) If the client is able to clarify the doubts and/or open issues from the Compliance Team, thetrading permission must be enabled. This step must be decided together with the AML Officer.
RISK-BASED APPROACH
ECOTERRA adopts and maintains a Risk-Based Approach (“RBA”) towards assessing andcontaining the money laundering and terrorist financing risks arising from any transactions it haswith users. The guidelines are as follows:
•

•
•

•
•

•

Before entering into any transaction or proposed transaction, necessary checks shall be
conducted in line with the RBA so as to ensure that the identity of the users does notmatch with any person with known criminal background or with banned entities such asindividual terrorists or terrorist organizations;
For the purpose of risk categorization of the users, the relevant information shall beobtained from the users at or before the time of entering into a transaction;
The risk categorization process for different types of users may take into account thebackground of the users, country of origin, sources of funds, volume of turnover ordeposits, as well as social and financial background;
The outcome of the risk categorization process shall be decided based on the relevant
information provided by the users at the time of commencement of business relationship;
Enhanced due diligence would be required for higher-risk users, especially those forwhom the sources of funds are not clear, or for transactions of higher value andfrequency, which shall be determined by ECOTERRA at its sole and absolute discretion;
and
ECOTERRA must be able to satisfy the competent authorities that due diligence wasobserved based on the risk profile of the ECOTERRA in compliance with the relevant
legislations in place.

MONITORING OF CLIENT ACTIVITY
In addition to gathering information from the users, ECOTERRA may have to continue tomonitor the activity of every user to identify and prevent any suspicious transactions. A

suspicious transaction is known as a transaction that is inconsistent with the user's legitimate
business or the usual user's transaction history known from user activity monitoring.
ECOTERRA has implemented the system of monitoring the named transactions (both automaticand, if needed, manual) to prevent using the company's services by criminals.
The company reserves the right to suspend any user's operation, which can be regarded as illegal
or, may be related to money laundering in the opinion of the staff.
INTERNAL CONTROLSECOTERRA implements and maintains internal controls for the purpose of ensuring that all of
its operations comply with AML legal requirements and that all required reports are made on atimely basis.
MONITORING AND REPORTING
ECOTERRA may have to diligently monitor transactions for suspicious activity. Transactions
that are unusual are carefully reviewed to determine if it appears that they make no apparent
sense or appear to be for an unlawful purpose. When such suspicious activity is detected, theCompliance Officer will determine whether a filing with any law enforcement authority isnecessary.
Suspicious activity can include more than just suspected money laundering attempts. Activity
may be suspicious, and ECOTERRA may wish to make a filing with a law enforcement
authority, even if no money is lost as a result of the transaction.
We will initially make the decision of whether a transaction is potentially suspicious. Once wehave finished his review of the transaction details, we make the decision as to whether thetransaction meets the definition of suspicious transaction or activity and whether any filings withlaw enforcement authorities should be made.
For the purpose of the Policies, a “Suspicious Transaction” means a transaction or attemptedtransaction, which to a person acting in good faith,••••

gives rise to a reasonable ground of suspicion that it may involve proceeds ofcriminal or other illicit activity, regardless of the value involved;
appears to be made in circumstances of unusual or unjustified complexity;
appears to have no economic rationale or bona fide purpose; andgives rise to a reasonable ground of suspicion that it may involve financing of theactivities relating to terrorism.

Automatic monitoring
The following rules are automatically checked by the system for every new incoming/outgoingtransaction:••

Total volume of a single user is > EUR 500’000.
Monthly volume of a user is > EUR 250’000.

••Full name and birth date do not appear on a Sanction + PEP list
Transactional Irregularities:- A transaction over EUR 20’000 after at least 3 transactions below EUR
1’000.
- 12 months no transactions, then more than 5 transactions within 30 days

A positive result on any of these automatic rule checks does not automatically lead to thedisabling of the trading permission and/or termination of the business relationship. The
Compliance Team and AML Officer are informed on any positive result of these checks. The
AML officer decides on further actions in these cases. It can trigger ECDD measures.
All PEP Lists, Sanction Lists and Cryptocurrency Address Blacklists are downloaded once perday, all existing users are checked against all lists on a daily basis automatically. If there is any
match, the specific user is automatically blocked from doing any transactions and theCompliance Team automatically receives an email with a warning. The Compliance Team thentries to clarify the situation by asking the user for proof that it is not a correct match with theSanction List, PEP List or Cryptocurrency Address Blacklist. If the user is unable to prove it, theuser remains blocked from doing any transactions. If the user made transactions before, the AML
Officer has to be notified by the Compliance Team. The AML Officer decides if the reporting of
the user is necessary.
Manual monitoring
Monitoring of high-risk users: For users that are already marked as high-risk, enhanced
monitoring of the business relationships with such clients is performed by the Compliance Team.
All transactions of such clients are being monitored closely and checked once per month. If there
are any irregularities, the Compliance Team can contact the AML Officer, who decides on
potential further action.
Asking the user for updated identification document: As we save the expiry date of the identity
document for all clients, we ask the client to send as the updated identity document at least 30
days before the document is expired. If the user cannot provide a new document until the expiry
date of the identity document, the business relationship is automatically terminated by thesystem.
Monthly random basis checks: Users and their transactions are subjected to a manual monthly
plausibility check on a random basis. The data and documents submitted and the transaction
history are checked. Client dossiers and the associated transactions are checked. The AML
Officer must be notified of any anomalies.
The client risk profile serves as a baseline for assessing potentially suspicious activity. The AML
Officer is responsible for this monitoring, reviews any activity that our monitoring system
detects, determines whether any additional steps are required, documents the resulting actions in
the client dossier, and reports suspicious activities to the competent authorities.
Rules

Rules which are checked in the manual checks which can – if violated – signal possible money
laundering or terrorist financing include, but are not limited to:• The client provides ECOTERRA with unusual or suspicious identification documents thatcannot be readily verified or are inconsistent with other statements or documents that theclient has provided. Or, the client provides information that is inconsistent with otheravailable information about the client. This indicator may apply to account openings and tointeraction subsequent to account opening.
• The client is reluctant or refuses to provide ECOTERRA with SCDD, CDD, ECDD
information as required by ECOTERRA’s procedures, which may include information
regarding the nature and purpose of the client’s business, prior financial relationships,
anticipated account activity, business location and, if applicable, the entity’s officers anddirectors.
• The client refuses to identify a legitimate source of funds or information is false,
misleading or substantially incorrect.
• The client has difficulty describing the purpose of his transactions.
• The client has been rejected or has had its relationship terminated as a client by otherfinancial services firms.
• The client’s background is questionable or differs from expectations based on businessactivities.
• The client maintains multiple accounts, or maintains accounts in the names of family
members.
• The client attempts or makes frequent or large deposits of currency, insists on dealing only
in cash equivalents, or asks for exemptions from ECOTERRA’s policies and procedures• The client seemingly breaks funds transfers into smaller transfers to avoid raising attention
to a larger funds transfer. The smaller funds transfers do not appear to be based on payroll
cycles, retirement needs, or other legitimate regular deposit and withdrawal strategies.
• The client makes a funds deposit followed by an immediate request that the money be
wired out or transferred to a third party, or to another firm, without any apparent businesspurpose.
• Wire transfers are made in small amounts in an apparent effort to avoid triggering
identification or reporting requirements.
• Upon request, a client is unable or unwilling to produce appropriate documentation (e.g.,
invoices) to support a transaction, or documentation appears doctored or fake (e.g.,documents contain significant discrepancies between the descriptions on the transport
document or bill of lading, the invoice, or other documents such as the certificate of origin
or packing list).
• A dormant account suddenly becomes active without a plausible explanation.
• Many small, incoming wire transfers or deposits are made using checks and money ordersthat are almost immediately withdrawn or wired out in a manner inconsistent with theclient’s history.

• The client exhibits unusual concern with ECOTERRA’s compliance with reporting
requirements and ECOTERRA’s AML policies.
• The client tries to persuade an employee not to file required reports or not to maintain therequired records.
• The client makes high-value transactions not commensurate with the client’s known
income or financial resources.
• The professional background or transactions of the client are not commensurate with thetype or level of activity of the client.
• The client engages in transactions that show the client is acting on behalf of third parties
with no apparent business or lawful purpose.
• The client engages in transactions that show a sudden change inconsistent with normal
activities of the client.
When an employee of ECOTERRA detects any red flag, or other activity that may be suspicious,
he or she will notify the AML Compliance Manager. Under the direction of the AML Officer,
ECOTERRA will determine whether or not and how to further investigate the matter. This may
include gathering additional information internally or from third-party sources, contacting thegovernment, freezing the account and/or reporting to the competent authorities.
Evidence
In case of doubt, the Compliance Team will make additional inquiries to verify the accuracy of
the information. The evidence listed below can be requested for this purpose.
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Annual net income
Liquid net assets
Net assets
Name and address of employer
Employment references

RECORD-KEEPING
We make sure that AML records are maintained properly.
We document our verification, including all identifying information provided by a user, themethods used and results of verification, and the resolution of any discrepancies identified in theverification process. We keep records containing a description of any document that we relied on
to verify a user’s identity, noting the type of document, any identification number contained in
the document, the place of issuance, and if any, the date of issuance and expiration date. With
respect to non-documentary verification, we retain documents that describe the methods and theresults of any measures we took to verify the identity of a user.
We also keep records containing a description of the resolution of each substantive discrepancy
discovered when verifying the identifying information obtained. We retain records of all
identification information for seven years after the account has been closed, or as long asreasonably necessary to comply with applicable regulations; we retain records made about
verification of the customer's identity for seven years after the record is made, or as long as
reasonably necessary to comply with applicable regulations.
TRAINING
New employees may receive anti-money laundering training as part of the new-hire training
program. All applicable employees are also required to complete AML training annually.
Participation in additional targeted training programs is required for all employees with
day-to-day AML and KYC responsibilities.
Our training includes, at a minimum: (1) how to identify red flags and signs of money launderingthat arise during the course of the employees’ duties; (2) what to do once the risk is identified(including how, when and to whom to escalate unusual customer activity or other red flags (3)what employees' roles are in ECOTERRA’s compliance efforts and how to perform them; (4)ECOTERRA’s record retention policy; and (5) the disciplinary consequences (including civil andcriminal penalties) for non-compliance.
Our operations are regularly reviewed to check whether certain employees require specialized
additional training. Written procedures are updated to reflect any such changes.
SANCTIONS POLICYECOTERRA is prohibited from transacting with individuals, companies and countries that are onprescribed sanctions lists. ECOTERRA will therefore screen against Canada, United Nations,
European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists
in all jurisdictions in which it will operate.